Determine the amount of u.s. taxable income for each entity

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Reference no: EM133505571

Entity

Country

Legal Form

Activity

Income

Before Tax

Income

Tax Rate

Dividend

Withholding

Tax Rate

Net Dividend

Received by

Parent

A

Bermuda

Corporation

Sales

$8,000,000

0%

0%

$8,000,000

B

Hong Kong

Corporation

Sales

$10,000,000

10%

0%

$9,000,000

C

Ireland

Corporation

Investment

$2,000,000

12.5%

0%

$1,750,000

D

Malaysia

Branch

Manufacturing

$10,000,000

24%

0%

$7,600,000

Additional information:

  • Entity A purchases finished goods from Entity D and sells them to other markets. 99% of A's income is from sales to foreign customers.
  • Entity B purchases finished goods from Entity D and sells them to other markets. 60% of B's income is from sales to foreign customers.
  • Entity C makes passive investments in stocks and bonds in European financial markets. All of C's income is derived from dividends and interest.
  • Entity D manufactures products that are sold in its home country as well as to related entities within the group.
  • The U.S. tax rate is 21%.

Required:

  1. Determine the amount of U.S. taxable income for each entity.
  2. Calculate the foreign tax credit allowed in the United States, by basket (branch income, general income and passive income) and in total.
  3. Determine the net U.S. tax liability on foreign source income.

Reference no: EM133505571

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